Financial Guidance for listed Issuers - what does COVID-19 mean?

Dato 15 mar. 2020
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While we do not yet know how much the COVID-19 will impact the financial markets, we do know that it has already had dramatic effects. It is of utmost importance that all issuers stay updated on what potential consequences COVID-19 may have on their businesses and financial guidance.

Many issuers have already added a description of the uncertainty regarding the impact of COVID-19 in their 2019 year-end financial reports and financial guidance.

Issuers should continuously consider whether the financial guidance that they have already made public should be either corrected or withdrawn as a consequence of the uncertainty that COVID-19 brings in relation to the issuers’ businesses.

We believe that any issuer’s financial guidance may be withdrawn based on a thorough analysis of the issuer’s current market conditions and the short term and midterm impacts of COVID-19. In many cases, the issuer’s current financial guidance will no longer be realistic and thus not compliant with the requirement that the market must always be updated on the issuer and the issuer’s securities. Hence, the issuer may in many instances be left with a choice of either updating the financial guidance or taking it down.

Should the issuer decide that the prudent thing to do is to take down the financial guidance, the company announcement should thoroughly explain why the guidance is being taken down. The company announcement should also aim to describe when such financial guidance will be updated and what criteria will trigger this.

11 March 2020, the European Securities and Markets Authority (“ESMA”) made the following recommendations to address the COVID-19 situation:

  1. Business Continuity Planning: All market participants should be ready to apply their contingency plans in order to ensure operational continuity in accordance with regulatory obligations.

  2. Market Disclosure: All relevant and significant information concerning the impacts of COVID-19 on prospects or the financial situation should be disclosed as soon as possible in accordance with the obligations regarding transparency and disclosure.

  3. Financial Reporting: The financial market participants should be transparent on the actual and potential impacts of COVID-19 on their financial situations and economic performance in either the 2019 year-end financial report ( if not yet finalized) or the interim financial reporting disclosures.

If you have any questions or would like additional information regarding the legal aspects, please feel free to contact Partner Dan Moalem (, Senior Associate Henning Hedegaard Thomsen ( or Junior Associate Jeanette Kjeldgaard Rasmussen (

The above does not constitute legal counselling and Moalem Weitemeyer Bendtsen does not warrant the accuracy of the information. With the above text, Moalem Weitemeyer Bendtsen has not assumes responsibility of any kind as a consequence of any reader’s use of the above as a basis for decision or considerations.